Neutrogena Skin360 Lawsuit Settlement, What the $4.7M BIPA Lawsuit Means for Users
If you ever used Neutrogena’s Skin360 app or website to get a personalized skin assessment, a $4.7 million class action settlement may be relevant to you. The lawsuit alleges that Skin360 secretly collected and stored users’ facial scans without their knowledge or consent, violating one of the strictest biometric privacy laws in the United States. Here is what happened, who is eligible, and what the settlement requires the company to do going forward.
What Is Skin360 and How Does It Work?
Skin360 invited users to complete a 180-degree facial scan using their smartphone camera or webcam. The software then analyzed their skin health and created a personalized “Skin360 score” through which users could receive skincare routine recommendations.
On the surface, it appeared to be a simple beauty tool. But according to the lawsuit, what happened behind the scenes was far more extensive. The biometric data collected was linked to personal information including the user’s name, birthday, and email address, as well as sleep schedules, exercise routines, stress levels, and geographic location. The data was also allegedly used to improve the company’s AI assistant, which learned about customers’ faces to recommend products — without users’ consent.
What Is BIPA and Why Does It Matter?
The Illinois Biometric Information Privacy Act (BIPA), passed in 2008, is one of the most protective biometric privacy laws in the country. BIPA ensures that individuals are in control of their own biometric data and prohibits private companies from collecting it unless they inform the person in writing of what data is being collected or stored, and inform the person in writing of the specific purpose and length of time for which the data will be collected, stored, and used.
In plain terms: if a company scans your face and stores that data, it must tell you clearly, explain why, and get your written permission first. Facial geometry — the unique measurements of your face — is treated under BIPA the same way a fingerprint is treated. It is permanent. If it is compromised, you cannot change it the way you would a password.
Who Filed the Lawsuit and What Did They Allege?
Between 2020 and 2022, four Illinois-based plaintiffs — Helene Melzer, Christine Borovoy, Andy Sajnani, and Patricia Biewald — each used the Skin360 application on their mobile devices. They alleged that the technology scanned, collected, captured, used, and stored digital copies of their unique facial geometries in an electronic database. They further claimed that J&J did not inform them in any manner that their biometrics were being captured, collected, stored, used, or disseminated.
The lawsuit was originally filed in May 2022 in New Jersey federal court under BIPA and for unjust enrichment. Plaintiffs sought an injunction stopping further violations, damages, and a jury trial.
J&J Tried to Get the Case Dismissed — and Failed
Johnson & Johnson attempted to have the case thrown out by arguing that Skin360 fell under BIPA’s healthcare exemption — meaning it should be treated like a medical tool rather than a consumer product. The court rejected that argument.
In a court opinion published March 7, 2025, Judge Michael Shipp noted that Skin360 relies on artificial intelligence to compare a user’s skin to a database of thousands of images, with no medical professionals involved. He ruled that users were not “patients” in a “healthcare setting,” and therefore the healthcare exemption did not apply.
That ruling was a significant turning point. With dismissal off the table, J&J — now operating as Kenvue following a 2023 corporate spinoff — moved toward settlement.
Related article: Prosper Data Breach Lawsuit, 17.6 Million Records Exposed, What Customers and Applicants Need to Know
Who Is Kenvue and Why Are They Paying?
J&J spun off its consumer division, which includes Neutrogena, into standalone company Kenvue in 2023. As the legal successor to J&J Consumer Inc., Kenvue inherited the liability for the Skin360 lawsuit. When settlement documents refer to the defendant, they reference both J&J Consumer Inc. and Kenvue Brands LLC interchangeably depending on the filing date.
What Does the $4.7 Million Settlement Include?
The proposed deal covers all individuals who, while in Illinois, performed a Skin360 skin assessment using any version of Skin360 — including Neutrogena Skin360, Neostrata Skin360, and any Skin360 collaborations with other entities — whether via mobile app or web browser, between December 9, 2019 and May 5, 2023.
Settlement documents estimate approximately 11,000 class members. If all eligible class members participate, each could receive approximately $427. That figure will be adjusted based on how many valid claims are submitted and after deductions for legal fees and administrative costs.
Beyond the cash payment, the settlement requires meaningful changes to how the company handles biometric data going forward. J&J Consumer must delete all images obtained during a Skin360 assessment during the class period. The company must also maintain a user notice and written consent mechanism for Skin360 and implement a written policy regarding the retention and destruction of biometric information.
Are You Eligible to File a Claim?
To qualify for the settlement, you generally need to meet all of the following:
- You used Skin360 — via mobile app or web browser — at any point between December 9, 2019 and May 5, 2023
- You were physically located in Illinois at the time of the scan
- The version you used includes Neutrogena Skin360, Neostrata Skin360, or any branded Skin360 collaboration
Class members must include with their claim form a written attestation under penalty of perjury that they were in Illinois and used the Skin360 tool during the class period. The settlement website and claim filing instructions were not yet live as of February 2026. Preliminary approval was requested on February 17, 2026, and the case is before Judge Michael Shipp in the U.S. District Court for the District of New Jersey.
This Case Is Part of a Broader Trend
The Neutrogena case is not an isolated incident. Beauty and tech companies have faced a wave of BIPA lawsuits in recent years as AI-powered “try-on” and skin analysis tools became mainstream. Sephora, L’Oreal, and several other major beauty brands have faced similar lawsuits over virtual try-on features that allegedly collected facial geometry data without proper consent.
The pattern highlights a significant gap between how quickly companies deploy AI-powered consumer tools and how carefully they think through the data privacy obligations those tools create. BIPA’s statutory damages — up to $5,000 per willful violation — make Illinois one of the most legally consequential states for companies deploying this technology without proper consent frameworks.
FAQs
What is the Neutrogena Skin360 settlement about?
The settlement resolves a class action claiming that Neutrogena’s Skin360 tool collected and stored Illinois users’ facial scan data without their informed written consent, in violation of the Illinois Biometric Information Privacy Act (BIPA).
Who is eligible for the $4.7 million settlement?
Illinois residents who performed a Skin360 skin assessment via mobile app or web browser between December 9, 2019 and May 5, 2023 are potentially eligible. This includes users of Neutrogena Skin360, Neostrata Skin360, and related branded versions.
How much will eligible class members receive?
If all eligible class members participate, each could receive approximately $427. The actual amount may vary based on total valid claims submitted and after legal fees and administrative costs are deducted.
Did Neutrogena or Kenvue admit wrongdoing?
No. As is standard in class action settlements, the company denied all allegations and agreed to settle to avoid the cost and uncertainty of continued litigation.
What is BIPA and does it apply outside Illinois?
BIPA is an Illinois state law. It applies to biometric data collected from people who are physically located in Illinois, regardless of where the company is based. If you used Skin360 while in another state, this particular settlement likely does not cover you — though other states are developing similar laws.
What will Neutrogena/Kenvue have to change going forward?
Under the settlement terms, the company must delete all facial images collected during the class period, create a written user consent form for Skin360, and establish a formal policy for how long biometric data is kept and when it is destroyed.
How do I file a claim?
The settlement website and claim instructions were not yet available as of late February 2026. Once the court grants preliminary approval, a settlement site will be launched. Checking ClassAction.org or the court’s PACER docket for updates is the most reliable way to stay informed.
Last Updated: March 3, 2026
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Laws and legal procedures vary by jurisdiction and may change over time. For advice regarding a specific situation, consult a qualified attorney or the appropriate authority.
About the Author
Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
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